Badger Trust responds to Defra Bovine TB consultation and calls for your support
Updated: Jun 23, 2020
Dear Badger Trust Friend,
We need your urgent assistance.
You may be aware of the Defra Bovine TB consultation on proposals to manage the delivery of both badger vaccination and culling in Edge counties. Badger Trust carefully reviewed the consultation documentation and has been speaking to badger vaccination groups to determine the impact on badger vaccination.
It is clear that the proposals are likely to:
enable culling across all Edge areas
severely limit any new schemes
damage the efficacy of current schemes and their ability to expand
damage the ability to continue at all for many current schemes.
This is a vitally important crossroads and Badger Trust will do all it can to prevent these proposals going forward.
We have produced our response to this consultation, with the following important points:
The consultation itself is fatally flawed; its intent is to enable culling in Edge areas, continue to expand in High Risk areas, and include additional reactive culling in Low Risk areas.
It seeks to prevent vaccinated badgers from being culled, instead of focussing on protecting vaccination schemes. Government should promote and expand badger vaccination as a priority, following the recommendations made in the Godfray Review.
The proposals to protect vaccinated badgers from being culled are completely inadequate, with the emphasis on ensuring that culling does not lose land to vaccination.
Although Badger Trust has responded to the consultation, we urge you to respond as individual responses carry much greater weight.
May we ask you to respond to this consultation urgently by the consultation end date of Friday, 26th June 2020?
The link to the consultation is here:
Our ‘Notes For Consideration’, below, include further question-by-question information that you may find helpful for your response.
With your help, we can all play a part in preventing these proposals and making our views known. Thank you.
With kind regards
Jo Bates-Keegan - Chair (for and on behalf of the board - Badger Trust)
Dominic Dyer - CEO Badger Trust
Notes For Consideration on ‘Bovine TB: consultation on proposals to manage the delivery of both badger vaccination and culling in Edge counties’.
The vaccination policy and consultation appears to be designed to facilitate further expansion of culling into edge areas and adjacent to vaccination schemes – notably following the recent NFU Judicial Review Court case, in which the culling of vaccinated badgers was highlighted.
Should the government persist with this policy, Badger Trust is in a position whereby we must give a specific response to questions relating to size, eligibility and where protection should be provided.
We consider this to be unacceptable and strongly object.
However, if we do not respond, we leave all vaccination schemes at risk of having no protection whatsoever. Other respondents may feel that buffer zones are wholly inadequate and that further responses are not required.
Following are notes relating to each consultation question that you may find helpful to consider when you respond.
Questions 1 to 4 relate to personal information and confidentiality.
Question 5: Should vaccinated badgers be protected from culling to some degree, to manage delivery of adjacent vaccination and culling?
You may wish to consider including the following points:
First: There is no scientific rationale for culling in the Edge areas.
A critical evaluation* of the Year End Epidemiology Report for Derbyshire, by Derbyshire Wildlife Trust made the following findings;
“In the Edge Area, the source was still most strongly ascribed to badgers (57%)...”
“The APHA vet assigned to each outbreak assesses the risk of exposure to M.bovis infection (Mycobacterium bovis, the causative agent of bovine TB) from badgers to cattle based solely on the presence or absence of badger activity in the vicinity of a herd breakdown. The vets have no detailed disease data for the badger population and have to make a large and unsupported assumption that badgers are a source of disease on essentially any farms where they are present....”
“The report fails to acknowledge the considerable volume of evidence pointing to the relatively poor sensitivity (the proportion of truly infected individuals in the screened population that are identified as infected by the test) of the single intradermal comparative cervical test (SICCT) in cattle and the implications for this in attributing pathways of infection. The limitations of the SICCT test mean that a proportion of infected cattle are not disclosed and a failure to adequately consider these factors may have resulted in an underestimation of the potentially important role of residual infection and cattle movements in the risk assessments for 2018.”
“The APHA report claims that there are endemically infected badger populations in Derbyshire, without citing scientific evidence to support the claim. A recent survey of road traffic accident badgers found that Mycobacterium tuberculosis complex (including M. bovis) was isolated from only 4% of dead badgers from across Derbyshire  (Professor Malcolm Bennett, personal communication).
Second: This proposal document does not take into account all impacts of culling on vaccination schemes, but concerns itself only with the potential negative effects on culling individual vaccinated badgers.
Both culling and badger vaccination schemes are licensed to prevent the spread of disease. Undermining the ability of the non-lethal method to do so, with a lethal method, is not rational or ethical, particularly given the stated desire to begin to replace culling with vaccination.
According to the RBCT (a study on which the government bases its justification for intensive culling), and other studies**, culling badgers cannot eradicate M.Bovis due to the fact that it increases the level of the disease in badgers. This is due to the breakdown of a stable clan structure and badgers ranging more widely (over 5km). Vaccination works most effectively in badgers that are not infected. Thus, culling undermines the positive effects that vaccination could have.
Any culling prior to or close to badger vaccination will reduce the number of badgers available to vaccinate each year (and appears to increase the number of trap-shy badgers, Tuyttens et al., 2001).
As badger vaccination in stable territories has been shown to have both a direct protective effect on vaccinated badgers and an indirect effect on unvaccinated cubs, it is likely that culling some vaccinated badgers will reduce that protective effect and any herd immunity which might have resulted from it.
Therefore the intended strategy in which badger vaccination and culling should take place within close proximity (or even together) is fatally flawed.
There are several practical issues with adjacent vaccination and culling, including:
a likely high landowner drop out rate from vaccination schemes, vaccinating groups are already reporting this has started with up to 50% loss in some areas;
badgers being culled within buffer zones due to an inability for NE to effectively monitor activity;
potential for intimidation of vaccinators and vaccinating landowners or damage to equipment;
impacts on the efficacy of badger vaccination schemes.
Question 6: If so, to what degree, in what circumstances and subject to what conditions? In particular –
(i) should any such protection only be provided to badgers vaccinated in the Edge Area?
It is Badger Trust’s belief that protection of badger vaccination in the Edge area should involve an end to new cull licences and the replacement of any potential supplementary cull licences with vaccination.
If you agree, you may wish to include a statement to this effect and some of the following, relating to other risk areas:
Vaccination is a much more effective alternative to culling as it does not increase the level of the disease in badgers. Badgers and badger vaccination schemes should be protected from culling in all areas.
High Risk Areas
Vaccination could be used to maintain disease levels in badgers as a follow up to intensive culling within high risk areas (as recommended by the Godfray Review), rather than supplementary culling.
Low Risk Areas
Badgers should not be culled in Low Risk Areas. In the Cumbria cull zone in 2018*** and 2016**** a total of 919 badgers were culled. Of the 676 badgers tested, only 42 (6%) were found to be positive for bTb. A total of 409 badgers in the outer area (termed a buffer zone) were tested (317 of which were culled in the 2019 season) and only 3 were found to be positive.
(ii) should protection be achieved by means of a no-cull zone?
You may wish to consider including the following;
Protection (of badger vaccination schemes and vaccinated badgers) should be achieved by replacing culling in the Low risk and Edge Areas and all culling in High Risk areas, with vaccination.
This should be achieved through a combination of increased support for voluntary groups, government partnership with landowners, and through the licensing of similar companies to those set up for culls.
Such an approach would face no public opposition and cost significantly less money.
We are particularly concerned that there has been an extremely limited monitoring of current culls and therefore cannot see how buffer zones could be policed.
Any vaccination scheme should be afforded enough room to protect the efficacy of the scheme and the badgers that will be vaccinated (or have been vaccinated).
We are aware that in one vaccination area, a buffer zone was not enforced and culling was found inside the buffer. Given NE monitoring has been almost non-existent within cull zones, we have no confidence whatsoever that they would be able to monitor and enforce buffer zones effectively and therefore culling within no-cull areas will inevitably take place whenever and wherever nobody is watching.
If buffer zones are implemented, they should be of large enough size to allow at least 7km wide protection and sufficient width to expand.
Vaccination schemes must be provided with enough information to report breaches and a suitable and effective means to do so.
As a condition of cull licences, breaches should lead to suspension or removal of contractors and repeated offences should lead to the suspension of the licence (although we cannot see how it could be policed).
(iii) if so, how should the size of the no-cull zone area be determined?
We suggest that you could refer to your previous answer; or you may feel that you wish to reject buffer zones altogether and ask them to replace it with vaccination.
Badger Trust would expect a minimum of 10km width in areas where culling is already taking place (this is based on badger ecology and a substantive expansion area), but of course it has been widely suggested that vaccination will begin to replace culling.
The size of all buffer zones should take into account the natural range of badgers from their setts (all setts within their territory, not just main setts), and any change in natural range that may occur as a result of culling.
In addition, the ability of a vaccination scheme to increase in size and also to join other schemes in order to create contiguous areas of disease protection.
(iv) should eligibility for a no-cull zone be subject to meeting certain minimum criteria?
We do not agree that there should be any minimum criteria.
You may wish to consider including the following;
It is well known that most vaccination schemes are volunteer led and start with only a small land covering.
This allows for funds to be raised, volunteers to increase and for additional farms to sign up over time.
It also allows for schemes to work towards a contiguous area which has been encouraged by the government scheme to provide financial support to groups:
“When considering applications, projects that are larger, or have the potential to become larger in time will be preferred. We will also prefer projects that have secured permission to vaccinate on connected land.” - BEVS2 Scheme Criteria
Badger vaccination is often seen as a stop-gap for culling, which prevents long term investment in the projects by landowners.
There is low confidence in badger vaccination in the farming community and a conflict between badger culling and vaccination. Any minimum size criteria would discourage and undermine efforts to vaccinate. Vaccinating landowners have already begun to drop out in some areas in anticipation of expanded culling.
Landowners who would not wish to cull under any circumstances may have invested significant sums of money in vaccination only to see the scheme fold and benefits lost, as too many badgers are culled.
Question 7: Do you have any comments on the proposed revisions to the Guidance (Annex A)?
You may wish to consider including some or all of the following points, depending on your previous responses;
Culls already present in any area should, following intensive culling (or supplementary culling) be replaced with vaccination.
Cull farmers are not disclosed to badger vaccinators, therefore it is difficult to see how they could negotiate an agreed approach. Also, most landowners stipulate confidentiality in order to take part.
Vaccinators should be provided with information on their buffer zone so that they can report any culling in those areas.
The requirement for landowners to sign up to a buffer zone is impractical because they will not know if there is a cull nearby.
We believe that this stipulation will also increase the drop out rate of landowners from vaccination schemes. This is because;
Landowners are usually reluctant to inform neighbours that they are taking part in a vaccination scheme. Removing confidentiality could place them at risk of intimidation or coercion.
Of those landowners who are not concerned about confidentiality, we would expect there to be high levels of interference. Just as there are members of the public who wish to prevent badger culling from going ahead, there are also those who will resort to criminal damage including vaccination equipment, abuse and intimidation of vaccinators, landowners and volunteers.
A vaccination scheme should not be in the position whereby it loses 30% of it’s vaccinatable population every year. Nor should it be told that if enough vaccinated badgers are culled, they will lose any protective buffer. This is a huge incentive for cull companies to destroy neighbouring vaccination schemes by bringing in extra cull contractors, or shooting in buffer zones illegally.
We do not support free-shooting under any circumstances, because it is not humane.
The suggestion that cage trapping only, adjacent to vaccination zones, would be ineffective. Marking badgers during vaccination involves fur clipping or stock marking and these are temporary, lasting a very short time. Even if a badger was very recently vaccinated, marks such as these (particularly fur clipping) can be easily confused with displaced fur or other marks (soil etc). In the dark, with a distressed animal, and whilst nobody is watching, it seems unlikely that a contractor would be well motivated enough to ensure that they avoid mistakes. Given a year on year decrease of monitoring in culls, we do not believe that this could be effectively policed or enforced.
We believe that it is now necessary for action that incentivises landowners to take part in vaccination initiatives. We also believe that the government should now invest in partnership working with cull companies to begin to vaccinate where four year culling is coming to an end.
It is now time, given the paucity of evidence to implicate badgers for spread of bTb, particularly in Edge areas, to cease cull operations in this area and allow farmers to form or convert to vaccination companies, working with government support.
Link to the online consultation:
* Critical evaluation of the Animal and Plant Health Agency report: ‘Year End Descriptive Epidemiology Report: Bovine TB Epidemic in the England Edge Area – Derbyshire 2018’
** Woodroffe, R. et al. BOVINE TUBERCULOSIS IN CATTLE AND BADGERS IN LOCALIZED CULLING AREAS Journal of Wildlife Diseases 45 (128-143) (2009)
*** TB surveillance in badgers during year 1 badger control operations in eastern Cumbria, Low Risk Area (2018) Published 21 March 2019
**** An update on TB surveillance in wildlife September 2019 and https://www.gov.uk/government/publications/bovine-tb-summary-of-badger-control-monitoring-during-2019/summary-of-2019-badger-control-operations
Full Badger Trust response to the consultation - pdf.